MARPA Members Issuing/Obtaining 8130-3 Tags – Here is Your Opportunity to Comment on the Next Revision to the Instructions

The FAA has released the latest version of the Order 8130.21 to the public for comment. DRAFT Order 8130.21H is the FAA guidance on how to complete an 8130-3 tag. Manufacturers that are issuing 8130-3 tags (through ODA, DAR, DMIR or any other FAA delegation) will want to review the proposed changes in the “H” revision to make sure that they are consistent with industry best practices.

The following list summarizes the proposed changes.

Section 1-1.c. adds a new note that states the use of the word “should” in the Order refers to a recommended practice. When the word “should” appears, the associated activity is not a requirement; therefore a record of completion of the activity is not required. Section 2-1.b. applies the word “should,” indicating use of FAA Form 8100-1 is a recommended practice, but not required.

Order 8130.21H creates a new appendix, labeled Appendix A. Appendix A collects all Sample FAA Form 8130-3’s and puts them in one place. In the previous Order, the sample forms were dispersed throughout the Order. The samples in Appendix A are re-numbered “Figure A-1,” “Figure A-2,” etc. In the previous Order, the Figure number corresponded to the Chapter of the Order in which they appeared, e.g., Chapter 2, Figure 2-1; Chapter 3, Figure 3-1.

The new Order also makes slight changes to the formatting of FAA Form 8130-3. The new form eliminates “Block 9. Eligibility.” Previously, this block remained but was “N/A” in most uses of the form. All of the following Blocks are incremented, e.g., “Block 10. Quantity” becomes “Block 9. Quantity,” and so forth (so the comment block will become known as “block 12”). The new Order re-numbers the signature blocks to be consistent with EASA Form One numbering format, so the left-hand signature blocks 14-18 become Blocks 13(a)-13(e), and the right-hand signature blocks 19-23 are renumbered as Blocks 14(a)-14(e).

The new Order changes the Date format in Blocks 13(e) and 14(e) from Month-Day-Year format to Day-Month-Year format, which reflects EASA Form One norms, but represents the opposite of ISO date format.

Chapter 3 of the new Order removes a Note from Section 3-1.b. that explained why rebuilt products and articles might not be found acceptable by some European countries. The Order adds a new Section 3-5 entitled “Approval for Return to Service Information Relevant to the European Union.” Section 3-5.a. explains that European Civil Aviation Authorities may recognize approval for return-to-service FAA Form 8130-3 only from 145 repair stations or air carriers that also obtained an EASA part 145 approval appropriately rated for the product or article at the time it was approved for return to service. Section 3-5.a.(2) gives specific instructions for completing FAA Form 8130-3 when a dual release is being applied to satisfy a European CAA (Euopean-created dual release) or EASA (extra-European dual release).

Section 3-5.b. addresses FAA Form 8130-3 for rebuilt engines within the European Union. Section 3-5.b.(1) gives brief background information on the aviation safety agreement between the U.S. and EU. The agreement allows for reciprocal acceptance of FAA and EASA certification and oversight of civil aviation products and repair stations. EASA now recognizes the term “Rebuilt Engines” as a manufacturing certification practice, not a maintenance release by the FAA. The agreement also places the same import requirements on rebuilt engines that are on new aircraft engines. 3-5.b.(2) gives specific instruction for completing FAA Form 8130-3.

Section 4-3 is renamed “Used Products and Articles” and updates the section to correspond to 14 C.F.R. § 21.331(c) & (d). Export airworthiness approvals for used aircraft engines, propellers, and articles are issued in accordance with § 21.331(c). If a used engine or propeller does not meet the requirements, § 21.331(d) allows for deviation if the importing jurisdiction accepts the deviation in a form and manner acceptable to the FAA. The deviation must be listed in Block 12. Remarks as an exception between the used aircraft engine or propeller from its approved design.

Section 5-6.a. & b. replace “part/component/assembly” with “engine/propeller/article.” Section 5-7 is reworded to reflect the elimination of XML code samples and direct the reader to Appendix A for examples of uses of Electronic FAA Form 8130-3. Section 5-8 re-labels the sample letter of intent to use electronic FAA Form 8130-3 from Figure 5-5 to Figure 5-1.

There is a lot for the industry to review and consider in this draft, and not all of the changes will be met with industry enthusiasm. This is a draft on which ASA members are likely to see a need for comments.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

Discussion

One thought on “MARPA Members Issuing/Obtaining 8130-3 Tags – Here is Your Opportunity to Comment on the Next Revision to the Instructions”

Hi Jason,
I just read through the proposed order and it does not appear to excise references to “ATA Spec 2000” but just the references to “Chapter 16″. It would make sense to remove references to the specific chapter in case Spec 2000 should re-number its chapters, but to leave the reference to Spec 2000 as the guiding standard.
Sean